The UK has published guidance in relation to the four UK sanctions regimes listed below. This guidance outlines the prohibitions and restrictions, the information and recording requirements, the circumstances in which a licence/authorisation may be obtained and how these sanctions will be enforced (along with the associated penalties).

  • ISIL (Da’esh) and Al-Qaida (United Nations Sanctions) (EU Exit) Regulations 2019: link to guidance
  • The Democratic Republic of Congo (Sanctions) (EU Exit) Regulations 2019: link to guidance
  • The Counter-Terrorism (International Sanctions) (EU Exit) Regulations 2019: link to guidance
  • Zimbabwe (Sanctions) (EU Exit) Regulations 2019: link to guidance

This supplements the guidance already published on other UK sanctions regimes (found here), specifically: Burma; Counter-Terrorism; Guinea-Bissau; Iran (Human Rights); South Sudan; and Venezuela.

These sanctions apply to those physically within the territory of the UK (regardless of nationality) and to the conduct of all ‘UK persons’ wherever they are in the world, which is defined to include British nationals, all bodies incorporated or constituted under the law of any part of the UK and branches of UK companies operating overseas.

So far, the guidance and, indeed, the sanction regimes themselves, appear to follow a standardised template form, with some variation in areas such as licence/authorisation that may be obtained in relation to each sanction.

Ross Denton is a Partner in the Firm’s EU, Competition and Trade Department in London. Ross was the former head of the Firm’s International Trade and WTO Practice Group, and now serves on the Firm’s Cartel Task Force. Ross also heads up the European Trade practice for the Firm. Ross routinely advises US and Japanese multinational corporations on competition law, export controls and sanctions, customs, bribery and corruption, and public procurement. Ross is a key member of the London office Anti-Bribery and Corruption Unit. Ross regularly speaks on trade and cartel issues, and has published widely on compliance related issues. He is a member of the UK Customs Practitioners Group.